Quijano v. Quijano, 347 S.W.3d 345

Guillermo Quijano Jr. and Marita Quijano married Sept. 23, 1993; they have one child.
Marita filed for divorce Apr. 10, 2009; Guillermo did not answer.
Default judgment hearing Sept. 25, 2009; Marita proposed division and testified; unsworn inventory.
Final decree largely adopted Marita’s proposed division and awarded Marita the marital home and other assets; Guillermo received assets in the Philippines and a business account.
Court ordered lump sum child support of $89,929.78 debited from Guillermo’s three community retirement accounts; two QDROs issued (ING and Prudential).
October 23, 2009 Guillermo moved for new trial; court denied but amended judgment for conservatorship.
March 17, 2010 amended QDRO addressed only the Prudential account and taxed distributions to the child; amended QDRO kept child as Alternate Payee and clarified tax responsibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the final decree’s property division was supported by adequate evidence.	Quijano: evidence for values was stale and insufficient.	Quijano: award values relied on outdated or inconsistent records.	No reversible error; six‑month-old Chase statement acceptable; division not manifestly unjust.
Whether the Bank of America account valuation conflicted with the decree.	Quijano: balance discrepancy meant improper award.	Quijano: decree awarded the entire account to Marita; no error.	Argument lacks support; decree awarded entire account to Marita; no error.
Whether including closing costs in valuing the family home was proper.	Quijano: closing costs should not be included absent sale intent.	Marita/Trial court: method not objected to; closing costs included.	No abuse of discretion; error not preserved or merits not shown.
Whether the decree could be divided without exact tax liability figures for 2008–2009.	Guillermo: needed tax amounts to divide taxes accurately.	Court could allocate tax aspects without exact future amounts.	Not an abuse; court may divide without precise tax figures.
Whether the amended QDRO violated Family Code §9.007 by altering the property division.	Amended QDRO changed alternate payee from Marita to child and tax allocation.	QDRO merely implemented the decree’s child-support mechanism and tax rules.	Amended QDRO did not alter substantive property division; valid enforcement order.

Mata v. Mata, 710 S.W.2d 756 (Tex.App.-Corpus Christi 1986) (reversals based on valuation errors; not controlling here)
Van Heerden v. Van Heerden, 321 S.W.3d 869 (Tex.App.-Houston [14th Dist.] 2010) (determine asset values as of close to date of divorce)
Kimsey v. Kimsey, 965 S.W.2d 690 (Tex.App.-El Paso 1998) (apportioning tax liability without exact amounts permissible)
Swaab v. Swaab, 282 S.W.3d 519 (Tex.App.-Houston [14th Dist.] 2008) (abuse of discretion standard in property divisions)
Mullins v. Mullins, 785 S.W.2d 5 (Tex.App.-Fort Worth 1990) (permissible to allocate tax liability without precise figures)